Winsor v. Sequoia Benefits & Ins.

"To establish injury in fact, a plaintiff must show that he or she suffered 'an invasion of a legally protected interest' that is 'concrete and particularized' and 'actual or imminent, not conjectural or hypothetical.'" Spokeo, 578 U.S. at 339 (quoting Lujan, 504 U.S. at 560).

Plaintiffs filed a class action alleging breach of fiduciary duty by Sequoia Benefits & Insurance Services, LLC, which managed a Multiple Employer Welfare Arrangement ("MEWA").  Plaintiffs are current or former employees of RingCentral, who participated in a RingCentral employee welfare benefits plan, a component of which was administered by Sequoia.  The district court dismissed Plaintiffs' initial and amended complaints for lack of Article III standing.  Plaintiffs appealed the dismissal of their ERISA claim. The Plaintiffs argued (1) they paid higher insurance contributions due to Sequoia's alleged breach of fiduciary duty; and (2) they have an "equitable interest" as beneficiaries of Sequoia's Tech Benefits Program trust that gives them standing to pursue relief.  "To establish injury in fact, a plaintiff must show that he or she suffered 'an invasion of a legally protected interest' that is 'concrete and particularized' and 'actual or imminent, not conjectural or hypothetical.'"  Spokeo Inc. v. Robins, 578 U.S. 330, 339 (2016) (internal citations omitted). The Court reasoned that Plaintiffs facts did not demonstrate actual injury by Sequoia because RingCentral controlled the Plaintiffs' contribution amounts and insurance coverage options. Plaintiffs second theory failed under Thole v. U.S. Bank, N.A., 140 S. Ct. 1615 (2020), in which the Supreme Court held that participants in a defined-benefit pension plan lacked standing to try an ERISA claim. Plaintiffs did not establish Article III standing. AFFIRMED.